State v. Taylor
Annotate this CaseDefendant pled guilty to driving under the influence (DUI). The offense occurred in 2011. After an enhancement hearing, the district court found that Defendant had three prior convictions and that the current DUI offense should be enhanced to a fourth offense. The court of appeals affirmed the conviction, concluding that, at the enhancement hearing, the State met its evidentiary burden in establishing Defendant's prior DUI convictions. The Supreme Court affirmed, holding (1) for purposes of enhancement of a DUI offense, the State is not required to provide an exact offense date for prior convictions, but rather, the State is required to prove by a preponderance of the evidence that the prior offense occurred within the twelve years prior to the offense for which the defendant is being charged; and (2) that the district court correctly found that the relevant evidence in this case made it more likely than not that one of Defendant's prior convictions pursuant to which his 2011 DUI offense was enhanced occurred within the twelve years of his 2011 DUI offense.
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